Legal Opinion

Joy Manufacturing Company v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided February 29, 1956No. 12-4497PublishedCited by 2 opinions

1Opinion of the Court

HASTIE, Circuit Judge.

In determining a deficiency in the 1949 income tax of Joy Manufacturing Company, the Commissioner of Internal Revenue ruled that a disputed item of $120,-277 constituted income accrued to the taxpayer during the taxable year for certain engineering services. The Tax Court sustained that ruling and the taxpayer has asked us to review the decision.

There is no serious disagreement about the essential facts as found by the Tax Court. Joy Manufacturing Company is a Pennsylvania corporation engaged in the manufacture and sale of mining and construction equipment and machinery.…

2Cases cited9 opinions

  1. Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
  2. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  3. Helvering v. SprouseSupreme Court of the United States · 1943
  4. Keasbey & Mattison Co. v. United StatesCourt of Appeals for the Third Circuit · 1944
  5. Commissioner v. Blaine, Mackay, Lee Co.Court of Appeals for the Third Circuit · 1944

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3Cited by2 opinions

  1. FEDERAL EMPLOYEES'DISTRIBUTING COMPANY v. United StatesDistrict Court, S.D. California · 1962
  2. Joy Manufacturing Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956

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